SITE-WIDE GROUNDWATER CORRECTIVE MEASURES STUDY WORK PLAN
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SITE-WIDE GROUNDWATER
CORRECTIVE MEASURES STUDY
WORK PLAN
TRADEPOINT ATLANTIC
SPARROWS POINT, MARYLAND
Prepared By:
TRADEPOINT ATLANTIC
1600 Sparrows Point Blvd
Sparrows Point, MD 21219
and
ARM GROUP LLC
9175 Guilford Road
Suite 310
Columbia, Maryland 21046
ARM Project No. 21010305
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TABLE OF CONTENTS
2.1 Site Setting and Use ......................................................................................................... 2
2.2 Nature and Extent of Contamination ................................................................................ 2
3.1 Overall Purpose of the Corrective Measures Study ......................................................... 4
3.2 Approach for Corrective Measures Study ........................................................................ 4
4.1 Corrective Action Objectives (CAOs) ............................................................................. 5
4.2 Target Media Cleanup Levels .......................................................................................... 5
6.1 Identification of Corrective Measure Alternatives ........................................................... 8
6.2 Additional Data Collection............................................................................................... 8
6.3 Evaluation of Corrective Measure Alternative(s) ............................................................ 8
Long-Term Effectiveness.......................................................................................... 9
Reduction in Toxicity, Mobility, or Volume of Wastes ........................................... 9
Short-Term Effectiveness ......................................................................................... 9
Implementability ....................................................................................................... 9
Community Acceptance ............................................................................................ 9
State Acceptance ....................................................................................................... 9
Cost ........................................................................................................................... 9
8.1 Project Personnel ............................................................................................................ 12
8.2 Project Schedule ............................................................................................................. 12
FIGURES
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APPENDICES
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INTRODUCTION
The Tradepoint Atlantic (TPA) Property encompasses approximately 3,100 acres located on a
peninsula situated on the Patapsco River near its confluence with the Chesapeake Bay. Numerous
groundwater investigations have been conducted of various areas of the overall TPA Property.
Two areas of the site, the Coke Point Area (CPA) and the Rod and Wire Mill Area (RWM), have
been the subject of on-going Interim Measures to address known groundwater impacts. Corrective
Measures Study (CMS) Work Plans have been submitted to focus on these two areas due to the
nature and extent of known groundwater impacts and the on-going Interim Measures to address
these impacts. These work plans are the:
Coke Point Area Groundwater Corrective Measures Study Work Plan (Rev. 1, January 14,
2021), and
Rod and Wire Mill Groundwater Corrective Measures Study Work Plan (Rev. 1, January
14, 2021).
This Site-wide Groundwater Corrective Measures Study Work Plan is intended to address groundwater
impacts identified on the overall TPA Property, other than in the designated CPA or the RWM areas.
1Tradepoint Atlantic Site-wide Groundwater CMS Work Plan
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CURRENT CONDITIONS
2.1 SITE SETTING AND USE
The TPA Property is located in Baltimore County, Maryland within the southeastern corner of the
Baltimore metropolitan area, and approximately nine miles from downtown. The property
encompasses approximately 3,100 acres of land located on a peninsula situated on the Patapsco
River near its confluence with the Chesapeake Bay, and physically positioned in the mouth of the
heavily industrialized and urbanized Baltimore Harbor / Patapsco River region. Figure 1 shows
the location and boundaries of the Tradepoint Atlantic property. Figure 2 shows the shaded area
to be covered in the Site-wide Groundwater CMS, and the relation to the CPA and RWM areas to
be addressed in separate groundwater CMS reports.
From the late 1800s until 2012, the property was used for the production and manufacturing of
steel. Iron and steel production operations and processes at the TPA Property included raw
material handling, coke production, sinter production, iron production, steel production, and semi-
finished and finished product preparation. In 1970, Sparrows Point was the largest steel facility
in the United States, producing hot and cold rolled sheets, coated materials, pipes, plates, and
rod and wire. The steelmaking operations at the facility ceased in fall 2012, and the steel mill has
been demolished. Current plans for the TPA Property include redevelopment over the next several
years. Some portions of the TPA Property have already undergone remediation and/or
redevelopment.
The TPA Property is currently zoned Manufacturing Heavy-Industrial Major (MH-IM) and current
uses on the Site include recovery of scrap metal, reclamation and processing of slag, and
stockpiling and handling of bulk commodity materials. There is currently no groundwater use
within the Site.
2.2 NATURE AND EXTENT OF CONTAMINATION
The nature and extent of groundwater impacts has been delineated in previous dedicated
groundwater investigations including the Area B Groundwater Phase II Study and the Finishing
Mills Area Phase II Study, as well as groundwater sampling conducted as part of the Phase II
studies of the numerous investigation parcels and supplemental NAPL and groundwater impact
delineation studies conducted on a number of the parcels. In addition, semi-annual groundwater
monitoring is conducted around the Greys Landfill in Parcel A12 and periodic NAPL gauging
has been conducted in areas where measurable NAPL has been identified. These numerous
reports have been submitted to the agencies for review and approval.
In addition, site-wide groundwater concentration maps have been prepared for various specific
key COPCs including benzene, naphthalene, Diesel Range Organics (DRO), chlorinated volatile
organic compounds (CVOCs), cyanide, zinc, cadmium, and hexavalent chromium. These figures
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have been provided via on-line GIS and present a good overview of current groundwater
conditions and identify areas of specific interest over the entire TPA Property for these key
constituents of potential concern (COPCs).
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PURPOSE
3.1 OVERALL PURPOSE OF THE CORRECTIVE MEASURES STUDY
This CMS will address groundwater impacts and sources of continuing releases to groundwater,
which may include NAPL or impacted soil, throughout the TPA Property outside of the RWM and
CPA areas that are being addressed by separate CMS reports. Other soil impacts and potential
exposures will be addressed through separate Phase II investigations and Response and
Development Work Plans (RADWPs). Assessment and remediation of historical offshore impacts
is being undertaken by the EPA and is not within the scope of this CMS.
3.2 APPROACH FOR CORRECTIVE MEASURES STUDY
The groundwater concern is volatile and semi-volatile organic compounds in the shallow and
intermediate zone groundwater. The approach to addressing groundwater during the CMS is to:
identify sources that need to be controlled to prevent cross-media transfer to
groundwater (e.g., soil to groundwater),
develop and evaluate alternatives to control continuing release of COCs to groundwater
from identified source areas, and
develop and evaluate alternatives to reduce levels of COCs in groundwater to the extent
practicable and migration of contaminated groundwater across the shoreline/property
boundary.
As noted, the CMS will address continuing discharges of groundwater but will not address impacts
already present offshore. These pre-existing offshore impacts are being addressed separately by the
EPA. The CMS will also evaluate exposure control measures (e.g., institutional and engineering
controls). These measures will be evaluated relative to their ability to control exposure in the
short-term, while other measures work towards the reduction of contaminant levels and extent over
time.
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CORRECTIVE MEASURES OBJECTIVES
4.1 CORRECTIVE ACTION OBJECTIVES (CAOS)
EPA expects final remedies to return usable groundwater to its maximum beneficial use, where
practicable, within a timeframe that is reasonable. Where returning contaminated groundwater to
its maximum beneficial use is not technically practicable, EPA generally expects facilities to
prevent or minimize the further migration of a plume, prevent exposure to the contaminated
groundwater, and evaluate further risk reduction. Technical impracticability (TI) for contaminated
groundwater refers to a situation where achieving groundwater cleanup levels associated with final
cleanup standards is not practicable from an engineering perspective. The term "engineering
perspective" refers to factors such as feasibility, reliability, scale or magnitude of a project, and
safety.
CAOs for the CPA are defined as follows:
(1) control further releases of constituents of potential concern (COPCs) to the
groundwater to the extent practicable,
(2) control human exposure to the hazardous constituents remaining in the groundwater,
(3) ensure that groundwater containing elevated concentrations of COPCs will not
adversely impact ecological receptors nor adjacent surface water and pore water
quality, and
(4) return contaminated groundwater to cleanup levels based on its maximum beneficial
use, to the extent practicable.
4.2 TARGET MEDIA CLEANUP LEVELS
Target Media Cleanup Levels and points of compliance will be developed during the CMS. The
CMS will propose media cleanup levels appropriate for the proposed CAOs and prepare figures
to identify the locations and extents of exceedances of the proposed media cleanup levels.
Potentially applicable standards and relevant criteria, and preliminary target levels and points of
compliance are discussed below.
EPA prepared a groundwater use determination memorandum dated April 13, 2018 (Appendix
A). EPA concluded that drinking water use of groundwater in the shallow and intermediate
aquifers at Sparrows Point can be excluded from consideration when developing groundwater
cleanup levels. The memorandum indicated that maximum beneficial use is industrial,
commercial or dewatering and that groundwater cleanup levels should be developed based on
State surface water quality criteria. The memorandum also indicated that more stringent
groundwater cleanup levels may be appropriate in specific areas of the Sparrows Point Site, based
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on other potential exposures or pathways not associated with groundwater use (e.g., vapor
intrusion or direct contact during construction excavation).
There is currently no direct exposure to groundwater for human receptors. Onsite industrial
workers may be exposed to vapors through vapor intrusion to indoor air, and construction workers
may have short-term exposure to shallow groundwater during intrusive work. Offsite ecological
receptors may have long-term exposure to pore water impacted by groundwater migration.
Therefore, with respect to potential human exposure, groundwater cleanup levels will be derived
for any constituents that might present an unacceptable risk due to vapor intrusion or to direct
contact during construction excavation or under a worst-case hypothetical commercial/industrial
exposure, such as the use of groundwater for equipment washing. The point of compliance for these
cleanup levels would be Site-wide.
With respect to potential industrial use and discharge of groundwater to surface water,
groundwater cleanup levels will be developed based on State surface water quality criteria. These
levels would serve as the target cleanup levels for restoration of groundwater to its maximum
beneficial use and would apply Site-wide. The CMS will evaluate a surface water mixing zone
in deriving these cleanup levels.
To protect ecological receptors, groundwater cleanup levels will be derived with a point of
compliance at the shoreline/property boundary to ensure that groundwater discharge will not
result in unacceptable risks to ecological receptors inhabiting the waters surrounding the CPA.
Various toxicological benchmarks, including the BTAG screening benchmarks for benzene, the
NOEC for DRO, and secondary chronic values for narcosis effects for naphthalene, as well as
other relevant aquatic screening criteria, will be considered, along with consideration of the
quality and size of the potentially exposed habitat areas, in determining acceptable COPC
concentrations applicable to specific exposure units. The CMS will evaluate attenuation factors
for groundwater to surface water and shallow pore water to determine appropriate shoreline
groundwater cleanup levels.
The CMS report will include figures delineating the specific areas of concern (AOCs) where
groundwater concentrations exceed these target media cleanup levels, and presenting the
distribution of contaminant concentrations.
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CORRECTIVE MEASURES TECHNOLOGIES
This section of the CMS Work Plan presents a description of the technologies planned for
evaluation in the CMS. The technologies presented include those technologies considered
applicable in addressing Facility contaminants, are likely to perform reliably and, will achieve the
CAOs presented in Section 4.0 of this CMS Work Plan.
The potential groundwater remediation technologies to be evaluated include:
Institutional and Engineering Controls
Restrictions on Groundwater Use
Restrictions on Site Use
Fencing/Warning Signs/Access Restrictions
Capping Waste or Contaminated Soils
Removal Technologies
Excavation
Product Recovery (Skimmers, EFR)
Groundwater Recovery (pump and treat)
Containment Technologies
Hydraulic Containment
Vertical Barrier Walls (sheet piling, soil-bentonite, etc.)
Sub-slab Vapor Barrier and/or Venting
Treatment Technologies
Air Sparge/Soil Vapor Extraction
In-Situ Chemical Treatment (reagent injection, soil mixing)
In-Situ Biological Treatment
Ex-Situ Treatment (CAMU)
Permeable Reactive Barriers
Disposal Technologies
Off-Site Disposal/Landfilling
On-Site Disposal (CAMU)
Permitted Discharge
A screening of these technologies will be presented in a summary table describing each technology
screened and the results of the screening to indicate which technologies are considered to be
potentially applicable based on applicability to the target COCs and the implementability of the
technology under the site conditions.
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IDENTIFICATION AND EVALUATION OF ALTERNATIVES
This section of the CMS Work Plan presents a general description of the approach for identifying
and evaluating potential corrective measure alternatives. Per applicable guidance, this section of
the CMS will present a description of each alternative and a brief screening of the identified
corrective measure alternatives against the RCRA threshold criteria.
6.1 IDENTIFICATION OF CORRECTIVE MEASURE ALTERNATIVES
Those technologies determined to be potentially applicable will be developed into Corrective
Action Alternatives. Identified technologies may be used alone or in combination to form the
overall corrective measure alternatives. The CMS may identify a current interim measure as, or
as part of, a final corrective measure alternative.
The CMS will describe the components of each corrective measure alternative including an
engineering description of each corrective measure alternative, a conceptual level design that will
form the basis for the estimate of potential cost for that alternative, how the alternative may be
expected to perform and, expectations regarding the time-frame for remediation.
These alternatives will be screened against RCRA’s threshold criteria which are:
1. protection of human health and the environment;
2. attainment of media cleanup objectives; and
3. controlling the sources.
6.2 ADDITIONAL DATA COLLECTION
No pilot or bench scale studies are currently anticipated. If an in-situ treatment technology is
identified for detailed evaluation, bench-scale treatability testing may be performed to assess the
efficacy and dosing of potential reagents.
6.3 EVALUATION OF CORRECTIVE MEASURE ALTERNATIVE(S)
This section will present a detailed evaluation of those alternatives determined to meet the
threshold criteria. Pursuant to applicable CMS guidance, the evaluation will address each of the
following evaluation/balancing criteria: long-term effectiveness; implementability; short-term
effectiveness; toxicity, mobility and volume reduction; community acceptance; state acceptance;
and cost.
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Long-Term Effectiveness
This criterion refers to the expected effectiveness, reliability and risk of failure of the alternatives,
including the effectiveness under analogous site conditions, the potential impact resulting from a
failure of the alternative, and the projected useful life of the alternative.
Reduction in Toxicity, Mobility, or Volume of Wastes
This criterion generally refers to how much the corrective measures alternatives will reduce the
waste toxicity, mobility and/or volume, primarily through treatment.
Short-Term Effectiveness
This criterion generally refers to potential short-term risks to on-site workers and the community
in association with implementation of the corrective measure alternatives, such as might be
associated with the excavation, handling, treatment, containment, and transportation of
contaminated materials.
Implementability
This criterion refers to the relative ease of alternative implementation (construction), including
duration, administrative and technical feasibility, and availability of the required services and
materials.
Community Acceptance
This criterion refers to the known or anticipated community acceptance associated with the
corrective measure alternatives. This criterion will be further evaluated through the 30-day public
comment period that will be provided following remedy selection and issuance of a Statement of
Basis by the EPA.
State Acceptance
This criterion refers to how the corrective measure alternatives will comply with applicable State
regulations (e.g., permit requirements).
Cost
This criterion addresses the anticipated short- and long-term costs associated with implementation
of the corrective measure alternatives.
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REPORT OUTLINE
The outline for the report is expected to be generally as follows:
1.0 INTRODUCTION
2.0 DESCRIPTION OF CURRENT SITUATION
2.1 Summary of Previous Investigations
2.2 Source Areas
2.3 Nature and Extent of Groundwater Impacts
2.4 Interim Measures
3.0 CORRECTIVE ACTION OBJECTIVES
3.1 Corrective Action Goals
3.2 Media Cleanup Levels and Point(s) of Compliance
4.0 IDENTIFICATION AND DEVELOPMENT OF THE CORRECTIVE MEASURES
ALTERNATIVES
4.1 Screening of Corrective Measures Technologies
4.2 Identification of the Corrective Measures Alternatives
4.3 Detailed Description of Each Alternative
4.3.1 Protection of Human Health and the Environment
4.3.2 Attainment of Media Cleanup Objectives
4.3.3 Control of Sources of Releases
4.4 Initial Screening of Alternatives
5.0 EVALUATION OF CORRECTIVE MEASURES ALTERNATIVES
5.1 Detailed Evaluation of Alternative 1
5.1.1 Long-Term Effectiveness
5.1.2 Reduction in Toxicity, Mobility, or Volume of Wastes
5.1.3 Short-Term Effectiveness
5.1.4 Implementability
5.1.5 Community Acceptance
5.1.6 State Acceptance
5.1.7 Cost
5.2 Alternative 2
5.3 Alternative 3, …
6.0 COMPARATIVE ANALYSIS AND PREFERRED ALTERNATIVE
6.1 Comparison of Alternatives
6.2 Technical Impracticability Assessment
6.3 Recommended Alternative
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6.4 Preliminary Implementation Schedule
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PROJECT ORGANIZATION AND RESPONSIBILITIES
8.1 PROJECT PERSONNEL
The Work Plan will be implemented by ARM Group LLC (ARM) under a contract with
Tradepoint Atlantic (TPA).
The TPA Project Manager is Mr. Peter Haid. Mr. Haid will be responsible for ensuring the
availability of resources for the project and will be the primary point of contact with the regulatory
agencies.
The ARM Project Manager, Mr. Neil Peters, P.E., is responsible for ensuring that all activities
are conducted in accordance with this Work Plan and the contract requirements. Mr. Peters is a
registered Professional Engineer in the State of Maryland and has served as Project Manager on
numerous remediation projects. As Project Manager, Mr. Peters will be responsible for technical
direction of ARM’s team of engineers and geologists, directing daily project activities, tracking
project schedule, and providing quality assurance. Mr. Peters will provide technical coordination
with the MDE, EPA and TPA.
8.2 PROJECT SCHEDULE
The additional data collection is anticipated to require approximately 16 weeks after agency
approval. If, after screening of technologies, it is determined that bench-scale or pilot-scale testing
is necessary, additional time may be required and a proposed schedule will be submitted.
12FIGURES
Site Boundary
Parcel Boundaries
Private Property
Parcel A9
Parcel A5
Parcel A13
Parcel A7 Parcel A14
Parcel A11 Parcel A8
Parcel A12 Parcel A2
Parcel A15
Parcel A17
Parcel A18
Parcel A16
Parcel A6
Parcel A4 Parcel A10
Parcel A3 Parcel A1 Parcel B6
Parcel B8
Parcel B14
Parcel B22
Parcel B16
Parcel B21
Parcel B15
Parcel B24
Parcel B23 Parcel B25
Parcel B7
Parcel B2
Parcel B1 Parcel B3
Parcel B17
Parcel B19
Parcel B4 Parcel B5
Parcel B9
Parcel B18
Parcel B10
Parcel B13
Parcel B20
Parcel B11
1
Parcel B12
Tradepoint Atlantic Figure
Area A and Area B Parcels
January 15, 2021
Tradepoint Atlantic
q
Sparrows Point
Baltimore County, MD
0 500 1,000 2,000 Area A: Project 200101
Feet Area B: Project 200102Site-wide Groundwater Area
Site Boundary
Parcel Boundaries
Private Property
Parcel A9
Parcel A13
Parcel A5
Parcel A7 Parcel A14
Parcel A11
Parcel A8
Parcel A12 Parcel A2
Parcel A15
Parcel A17
Parcel A18
Parcel A16
Parcel A6
RWM Parcel A4 Parcel A10
Parcel A3 Parcel A1
Parcel B6
Parcel B8
Parcel B14
Parcel B21 Parcel B22
Parcel B16
Parcel B24
Parcel B15
Parcel B23
Parcel B7 Parcel B25
Parcel B2
Parcel B1 Parcel B3
Parcel B17
Parcel B19
Parcel B4 Parcel B5
Parcel B9
Parcel B18
Parcel B10
Parcel B13
CPA Parcel B20
Parcel B11
2
Parcel B12
Tradepoint Atlantic Figure
Area A and Area B Parcels
January 15, 2021
Tradepoint Atlantic
q
Sparrows Point
Baltimore County, MD
0 500 1,000 2,000 Area A: Project 200101
s, CN
Feet Area B: Project 200102APPENDIX A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029
SUBJECT: Groundwater Use Determination April 13, 2018
Sparrows Point Site (Tradepoint Atlantic)
Sparrows Point, MD
MDD053945432
FROM: Erich Weissbart, P.G.
Project Manager
Office of Remediation
TO: Luis Pizarro
Associate Director
Office of Remediation
Introduction
The purpose of this memo is to establish the basis for determining the maximum beneficial use
of groundwater at the Sparrows Point Site located in Sparrows Point, MD. This determination is
necessary to select appropriate groundwater cleanup objectives for the facility under the
Resource Conservation and Recovery Act (RCRA) Corrective Action program.
EPA policy for groundwater cleanup at RCRA Corrective Action facilities is to return usable
groundwater to its maximum beneficial use in a timeframe that is reasonable given the
circumstances of the site. A determination of maximum beneficial use is based on how
groundwater is actually used or could be used, and should also be based on the hydrogeologic
and geochemical characteristics of the groundwater aquifer. EPA prefers to rely on State
groundwater use determinations, but can use its own in the absence of a State determination.
The policy applies to impacted aquifers beneath a Corrective Action facility, however there are
sites where it applies offsite as a result of migrating contaminant plumes. The majority of RCRA
Corrective Action facilities are required to restore contaminated groundwater to levels acceptable
for drinking, since drinking water is generally the most beneficial use of groundwater, requiring
the lowest cleanup levels. However, groundwater cleanup levels can also be based on other uses
and exposures, or to protect surface water to which groundwater discharges.
Without a formal aquifer use determination at the Sparrows Point facility, EPA’s presumption is
that the groundwater is usable as drinking water and must be restored to drinking water
standards. Likewise, Maryland Department of the Environment Interim Final Guidance, Cleanup
Standards for Soil and Groundwater (June 2008) defines aquifers of the State as Type I and Type
II, which would also require the groundwater beneath Sparrows Point be restored to drinkingwater standards. The remainder of this memorandum is to present the basis for excluding drinking water use from consideration at Sparrows Point and thereby establish alternative uses upon which to base groundwater cleanup levels. This groundwater use determination applies to impacted groundwater from immediately below the land surface at Sparrows Point, called “shallow” in historical reports, and groundwater immediately beneath the shallow called “intermediate” in historical reports. This document will define the depths of these two aquifers, the basis for the determination, and the basis for limiting the determination to the shallow and intermediate aquifers. Once this determination is made and accepted by stakeholders, groundwater cleanup levels will be proposed in a Statement of Basis (SB) proposing a remedy for sitewide groundwater. Once the usage determination and groundwater cleanup objectives are proposed, both will go through public participation as part of the proposed remedy decision for groundwater. If groundwater use as drinking water is excluded as a basis for setting cleanup levels, an important component of final remedies is to establish institutional controls that prevent the usage of groundwater for potable use. Restrictions can be placed on the land using enforceable controls (e.g., with environmental covenants) preventing the installation of any types of wells other than monitoring wells, preventing the use of groundwater for anything other than monitoring and cleanup, or requiring treatment before use or discharge. However, the groundwater must still ultimately be restored to the cleanup objectives established for other potential uses and exposures, or attempts made to achieve the groundwater cleanup levels. Background Sparrows Point is a unique RCRA site in that that it is much larger than most, greater than 3,000 acres in areal extent, and it is surrounded by water on three sides. Sparrows Point is a peninsula, bounded to the east by Old Road Bay and Jones Creek; to the south and west by the Patapsco River; and to the northwest by Bear Creek, all of which directly or indirectly drain into the Chesapeake Bay. Throughout most of the peninsula, the elevation of the ground surface is between 10 and 20 feet above mean sea level (amsl). Surface water runoff is diverted and collected by a network of culverts, underground pipes, and drainage ditches within former process areas. Storm water is then discharged to Bear Creek, Jones Creek/Old Road Bay, and the Patapsco River under existing National Pollutant Discharge Elimination System (NPDES) discharge permits. In 1887 Maryland Steel built an iron furnace on the Facility, and the first iron was cast in 1889. The Bethlehem Steel Corporation (BSC) purchased the property in 1916 and enlarged it, building mills to produce hot rolled sheet, cold rolled sheet, galvanized sheet tin mill products, and steel plate. During peak production in 1959, BSC operated 12 coke oven batteries, 10 blast furnaces, and four open hearth furnaces. The land no longer resembles that which was initially encountered prior to construction of the steel mill in the late 1800’s, nor does the Facility resemble that which terminated steel making in 2012.
Geology and Hydrogeology The Sparrows Point Facility lies within the Atlantic Coastal Plain physiographic province. This province is characterized by a relatively thick wedge of alternating layers of sand, gravel, silt, and clay sediments. Near Baltimore, these unconsolidated sediments are primarily of Cretaceous age, but at Sparrows Point are overlain by up to 125 feet of later Pleistocene sediments. These complexly stratified deposits comprising the Atlantic Coastal Plain form an inter-layered sequence of aquifers and confining beds in a thickening wedge from the “fall line” to the southeast. The lithology, permeability, and structure of the sediments define the geologic setting and provide the framework for the groundwater- flow system. The geologic setting controls the occurrence, movement, and quality of groundwater. Predominantly sandy and gravelly layers, capable of yielding water, form aquifers, while fine-grained layers (silts and clays) impede the flow of groundwater and form confining units. Stratigraphy at the site from deepest to shallow begins with crystalline basement rocks that are unconformably overlain by the Patuxent Formation, which is conformably overlain by the Arundel Formation. The Arundel Formation is disconformably overlain by the Patapsco Formation, which represents uppermost Cretaceous-age sediments. The Patuxent, Arundel, and Patapsco Formations are collectively called the Potomac Group. Pleistocene sediments of the Talbot Formation unconformably overlie the Cretaceous sediments. The thickness of the Atlantic Coastal Plain sediments vary across the site but notably, for the purpose of this memorandum, the shallow, intermediate, and deep aquifers investigated at Sparrows Point comprise sediments approximately 220 feet to 270 feet thick and are underlain by the Arundel Formation. The Arundel Formation, or Arundel Clay, is the middle unit of the Potomac Group. In the Baltimore area, it is a red to red-yellow, dense, plastic clay with thin lenses of silt. The Arundel Clay completely confines the Patuxent Formation and subsequent aquifers beneath. Land reclamation and fill placement have occurred at the Facility since the early 1900s. In general, stream channels and estuaries that originally extended into the Sparrows Point peninsula were filled; the southern shoreline of the peninsula was expanded southward into the Patapsco River with fill; and fill was used to create level grades (Figure 1). The fill deposits are thickest (up to 40 feet) in the historic stream channels and estuaries, particularly Humphrey Creek, Greys Creek, Jones Creek, and Old Road Bay and in the two landfill areas, including Greys Landfill and Coke Point Landfill, where fill thickness may be as thick as 70 feet. More recent fill deposits are entirely manmade and were related to land reclamation associated with the expansion and development of the facility. The fill deposits consist primarily of iron- and steel- making slag. Because of its extensive presence across the Sparrows Point site, these manmade fill deposits are called the Slag-Fill Unit. The Slag-Fill Unit is the uppermost hydrostratigraphic unit at the site. The shallow water table occurs within the Slag-Fill Unit, and groundwater within the Slag-Fill Unit is unconfined. In some areas the Slag-Fill Unit is directly underlain by and connected to the coarser grained beds or lenses within the Pleistocene Talbot Formation that comprise the Upper Talbot Channel Unit. In these areas, the Slag-Fill and Upper Talbot Channel Units form a single groundwater flow system. In much of the site, the Slag-Fill unit is underlain by finer-grained silts and clays that comprise the Talbot Clay Aquitard. In these areas, groundwater flow in the Slag-Fill Unit is separated from groundwater flow in any underlying coarse-grained beds or lenses. Wells
designated as shallow are screened within the slag/fill unit. The “shallow” bottom-of-screen elevations generally range from +5 to -20 feet amsl. The thickness of the Talbot deposits (125 feet in the Sparrows Point area) may indicate an area of deeper paleo-channel erosion and subsequent backfill. The intermediate hydrogeologic zone includes the unconfined to partially confined groundwater in the Upper Talbot unit. The “intermediate” bottom-of-screen elevations generally range from -20 to -50 feet amsl. The presence of clay and silt layers within the intermediate hydrogeologic zone likely retard the vertical recharge of groundwater from the upper fill material. The lower hydrogeologic zone includes the confined groundwater in the Lower Talbot or Upper Patapsco Sand unit. At Sparrows Point the Patapsco Formation has been interpreted to have a thickness of up to 255 feet. The “lower” bottom-of-screen elevations generally range from -50 to -141 feet amsl. Hydrogeologic zones at greater depth are known to exist based on a review of the regional geology; however, these deeper units are isolated from the upper three units by the Arundel Clay and impacts have not been identified from former operations. Aquifers in the Patuxent and Patapsco Formations are the primary groundwater sources in the Baltimore area. Local water supplies can be produced from the Talbot Formation, however where the Talbot Formations outcrop close by to estuaries, nearby water supply wells are susceptible to chloride contamination. No municipal water supply wells are located on the Sparrows Point peninsula. Elevated chloride concentrations in the Talbot Formation are wide- spread along the Patapsco River and its estuaries, and salt-water encroachment is a significant factor limiting the development of water supplies in the Talbot Formation. Groundwater recharge to the Talbot Formation occurs primarily through the percolation of local precipitation to the water table. It is estimated that approximately 10 inches of rainwater per year recharges the surficial shallow water table aquifer. Discharge is primarily by natural means to springs and surface waters of local rivers, streams, and estuaries. The Patapsco Formation is also a source of groundwater for the Baltimore area. A sand facies in the lower part of the Patapsco Formation is considered the principal source of water for the Patapsco aquifer. The Patapsco aquifer is confined at Sparrows Point by the overlying Pleistocene Talbot sediments that serve as the upper confining bed, and the Arundel Formation defines the lower confining bed. The Patapsco aquifer was used as a source of groundwater prior to 1900 and during the early part of the 20th century. Because the Patapsco aquifer widely subcrops beneath the brackish Patapsco River, elevated chloride concentrations became a major problem in areas near the Patapsco River estuary. By 1945, almost all water production from the Patapsco had ended due to excessive chloride near the Harbor, Canton, and Dundalk areas. The BSC plant was the only major user of the Patapsco aquifer in 1945. Water production totaled about 3 million gallons per day (Mgal/d); however, by the later 1940’s and 1950’s, many of the Sparrows Point wells were affected by elevated levels of chlorides and were abandoned. As of 1985, there were no major use of the Patapsco aquifer in the immediate vicinity of the Patapsco River estuary.
Usage Current There is no current ongoing usage of groundwater beneath the Facility, but there is groundwater extraction at an adjacent property as described below. Groundwater is monitored for various purposes on a regular frequency to assess remediation efforts at the former Rod and Wire Mill and Coke Oven Area.; regular groundwater monitoring also occurs at Greys Landfill. Across the entire Sparrows Point facility there are dozens to hundreds of monitoring wells constructed into the shallow aquifer and a lesser number into the intermediate aquifer. There are few monitoring wells constructed into the deeper aquifer. There are no monitoring wells into the Arundel Formation and none into the Patuxent below the Arundel. There are six deep production wells constructed into the Patuxent, but none are currently in use. An adjacent property called Sparrows Point Shipyard (Shipyard) contains a "graving dock," used for the repair or scrapping of ships under dry conditions. Ships enter the graving dock when it is filled with water, via the Patapsco River, and then a gate is closed and water is removed. A central feature of the graving dock is the underdrain pumping system. The underdrain pumping system collects groundwater and pumps the water to the Patapsco River. The Shipyard's pumping system causes groundwater from the Coke Oven Area of Sparrow’s Point to flow towards the graving dock. The discharge of the water from the underdrain pumps to the Patapsco River is regulated by the Clean Water Act; specifically by a NPDES discharge permit issued by MDE. Because of sampling performed by MDE in 2005 where high concentrations of benzene were detected in the discharge, a 2006 permit renewal included a discharge limit of 0.51 mg/1 on benzene in certain graving dock discharges that applied to dewatering/trim pumps, and not to the underdrain pumping system. In January 2009, MDE revised the permit to impose the same 0.51 mg/1 limit to the underdrain pump discharge, and the revision went into effect in February 2010. To comply with the benzene limitation, the Shipyard installed a benzene treatment system that removes benzene from the groundwater. The Shipyard operates the water treatment system to remain within the 0.51 mg/1 benzene limit imposed by MDE, however the need for the treatment is caused by the operation of the graving dock. The Shipyard pump systems remove an average rate of 750 gallons per minute (i.e. roughly 1.08 Mgal/day). The influence from the dewatering system at the graving dock on water levels in the intermediate zone of groundwater in the Coke Oven Area is depicted on the potentiometric figures created from monitoring well water levels measured over time and submitted by the Facility in investigations and progress reports. Influence on the shallow zone of groundwater is not apparent. This condition is attributed to: location of the pumps at depths that correspond with the stratigraphy of the intermediate unit and decreased recharge from the Patapsco River, and the partially-confined condition of the intermediate zone in this area. The spread of a cone of depression from a pumping center under partially-confined conditions occurs more quickly than that under unconfined conditions. The influence of the graving dock pumping is observable over 2,000 feet away, where flow in the Coke Oven Area is shifted to the northwest in the intermediate zone, while flow in the shallow zone is to the southwest.
Potential Future Usage
Groundwater beneath the Sparrows Point Facility has value as a resource whether it is potable
use or another use. How groundwater could be used depends upon multiple factors: vulnerability
to contamination; hydrogeologic regimes (recharge and discharge areas); flow patterns; quantity
and potential yield; ambient and/or background quality; and existing contamination are some 1 . If
each factor were addressed satisfactorily (e.g. sufficient quantity and yield and absence of
contamination) then the groundwater could potentially be a potable source. However, if some
factors were met successfully and others were not the groundwater could still have potential
uses. The following list of groundwater uses was collected from the United States Geologic
Survey and MDE:
1. Public and domestic supply - water used for indoor and outdoor household purposes—
all the things you do at home: drinking, preparing food, bathing, washing clothes and
dishes, brushing your teeth, watering the yard and garden.
2. Aquaculture water use is water associated with raising creatures that live in water—such
as finfish and shellfish—for food, restoration, conservation, or sport.
3. Industrial water use includes water used for purposes such as fabricating, processing,
washing, diluting, cooling, or transporting a product; incorporating water into a product;
or for sanitation needs within the manufacturing facility. Some industries that use large
amounts of water produce such commodities as food, paper, chemicals, refined
petroleum, or primary metals.
4. Irrigation water is essential for keeping fruits, vegetables, and grains growing.
Throughout the world, irrigation (water for agriculture, or growing crops) is probably the
most important use of water. Estimates vary, but about 70 percent of all the world's
freshwater withdrawals go towards irrigation uses
(http://www.globalagriculture.org/report-topics/water.html). Large-scale farming could
not provide food for the world's large populations without the irrigation of crop fields by
water gotten from rivers, lakes, reservoirs, and wells.
5. Livestock water use is water associated with livestock watering, feedlots, dairy
operations, and other on-farm needs. Livestock includes dairy cows and heifers, beef
cattle and calves, sheep and lambs, goats, hogs and pigs, horses, and poultry. Other
livestock water uses include cooling of facilities for the animals and animal products such
as milk, dairy sanitation and wash down of facilities, animal waste-disposal systems, and
incidental water losses.
6. Mining water use is water used for the extraction of minerals that may be in the form of
solids, such as coal, iron, sand, and gravel; liquids, such as crude petroleum; and gases,
such as natural gas. The category includes quarrying, milling (crushing, screening,
washing, and flotation of mined materials), and other operations associated with mining
activities.
1 Factors to Assess Use, Value, and Vulnerability from: Handbook of Groundwater Protection and Cleanup Policies
for RCRA Corrective Action; EPA 530-R-04-030; April 2004. Current use and exposures (including public water
supply systems and private drinking water supply wells); Reasonably expected future uses (based on
demographics, remoteness, and availability of alternative water supplies; Connections to surface waters; Impacts
to ecological receptors; Value attributed to a groundwater resource, including public opinion; Governmental and
legal boundary considerations (e.g., groundwater migrating
across State boundaries).Value Because of the native unconsolidated sediments where groundwater is resident on the peninsula there is groundwater available for the typical uses described above. It is reported that BSC previously extracted 3 Mgal/d from the Patapsco Aquifer and the Shipyard currently extracts approximately 1 Mgal/d from the intermediate aquifer located in the Talbot Formation. Equally apparent from the former and current usage is that unconsolidated sediments possess the hydrogeologic characteristics necessary to extract groundwater at a sustainable rate. Aquifer characteristics are less important, as are most of the factors, than an assessment of the background quality of the groundwater. Groundwater background quality is the most important factor because the shallow aquifer resides in iron/manganese bearing slag fill and because the Sparrow’s Point peninsula is surrounded by brackish water. Background is the condition of groundwater including water quality indicators prior to the introduction of anthropogenic contamination. Water quality standards, i.e. pH, turbidity, temperature, etc. are typically collected from monitoring wells prior to groundwater sample collection. The purpose of collecting water quality indicators is to establish that a monitoring well groundwater sample reflects the conditions of an aquifer and not the well bore. The water quality indicators are recorded as evidence of proper sample collection. In this effort to assess groundwater usage at the Sparrow’s Point site, EPA requested an evaluation of site-wide groundwater, including an analysis of pH and total dissolved solids (TDS), from the current property owners. The Site-Wide Groundwater Study Report, (EnviroAnalytics Group (EAG) August 17, 2017), was submitted in response and included the requested groundwater data for both the shallow and intermediate aquifers as detailed below. The EAG Report included an evaluation of boring logs and well construction logs constructed in the shallow aquifer that identified groundwater monitoring locations completed in the slag fill. The purpose was to determine and map the thickness of slag fill within the saturated zone. The conclusion presented was that most of the locations where groundwater is present in slag fill are located beyond the historical 1916 shoreline (Figures 1 and 2). A Site-Wide Investigation (SWI) report completed in 2001 by CH2M-Hill provided hydrogeological and general water quality data across the entire Sparrow’s Point Facility and addressed a number of objectives. Data collected to meet the objectives were used to develop a site-specific groundwater flow model with particle tracking simulating contaminant flow (MODFLOW). Water quality data collected to address the objectives were TDS and chloride concentrations from shallow and deep zones for comparing groundwater quality and determining surficial and groundwater connectivity. The chloride and TDS data from the SWI report were combined with specific conductance (SC) data collected during the routine sampling of monitoring wells as part of current ongoing parcel investigations. The SC data that was collected during parcel investigations was converted to equivalent TDS values (1000 uS/cm = 534 mg/L TDS). These data points were used to develop TDS isoconcentration maps for the shallow and intermediate groundwater (Figures 3 and 4).
Groundwater associated with slag fill can exhibit extremely basic pH concentrations rendering it unusable. pH values collected from recent sampling events from each well or piezometer were contoured to create maps (shallow and intermediate) showing pH contours and delineating areas of the site where the pH exceeds 10 (Figures 5 and 6). These areas/zones are not usable as potable aquifers, both due to the high pH and the occurrence of the groundwater in non-natural slag fill which additionally contributes iron and manganese. Iron and manganese (Fe/Mn) are common in shallow and intermediate groundwater at Sparrows Point. Manganese was detected in 95% of groundwater samples and iron was detected in 94% of groundwater samples. High levels of iron and manganese do not pose any known adverse health risks and EPA has not set MCLs for iron and manganese; however there are Project Action Levels (PALs) established as screening levels for the Facility. Secondary maximum contaminant levels (SMCL) recommended in the National Secondary Drinking Water Regulations are set for aesthetic reasons and are not enforceable by EPA, but are intended as guides to the States. The SMCL for iron is 0.3 mg/L (site-specific PAL is 14 mg/L) and the SMCL for manganese is 0.05 mg/L (site-specific PAL is 0.43 mg/L). High levels of these contaminants can result in discolored water, stained plumbing fixtures, and an unpleasant metallic taste to the water. For groundwater samples collected at Sparrows Point, 47% exceeded site-specific PALs for manganese and 30% exceeded PALs for iron. Saltwater intrusion was an issue at the Facility previously because of historical pumping for industrial water use. Data and analysis have been provided showing total dissolved solids and pH in groundwater across the site in the shallow and intermediate levels. Based on this data, (TDS and pH) shallow and intermediate groundwater is not suitable for potable use, primarily because of the largely man-made slag fill contributing elevated pH, Mn, and Fe, but also because of the connection to surface water and elevated chloride. The groundwater in these areas is not suitable for potable use. The table below summarizes the potential uses of groundwater in the shallow and intermediate zones, the potential cleanup standard that would have to be attained, and EPA’s determination of usage.
Designation Standard Shallow Use Intermediate Use
Domestic Potable MCLs No. Shallow No. Intermediate
Supply and groundwater contains groundwater contains
Residential excess TDS and elevated TDS.
Irrigation elevated pH
Farming (Livestock Ecological RBC No. Shallow No. Intermediate
Watering and or other risk groundwater contains groundwater contains
Agricultural based std. excess TDS and both elevated TDS.
Irrigation) low and high pH
Industrial, State Surface Yes. Yes. Current
Commercial, Water Quality dewatering at Sparrows
Dewatering (Mining, Discharge Point Shipyard.
aquaculture) Standards
Public Water Supply MCLs No. Shallow No. Intermediate
Well groundwater contains groundwater contains
excess TDS and both elevated TDS.
low and high pH
Test, Observation, None Yes Yes
Monitoring
Open Loop State Surface yes yes
Geothermal2 Water Quality
Discharge
Standards
Conclusion
Based on the above analysis, EPA has determined that drinking water use of groundwater in the
shallow and intermediate aquifers at Sparrows Point can be excluded from consideration when
developing groundwater cleanup levels. Maximum beneficial use should include the uses
outlined in the above table, and groundwater cleanup levels should be developed based on State
surface water quality discharge standards. More stringent groundwater cleanup levels may be
appropriate in specific areas of the Sparrows Point Site, based on other potential exposures or
pathways not associated with groundwater use (e.g., vapor intrusion or direct contact during
construction excavation).
2
The evaluation of geothermal systems is beyond the scope of this memorandum. In the case where the Facility or a
Parcel owner/lessee proposes to use groundwater for geothermal heating or cooling EPA will then assess the
viability of the proposal.q
Site Boundary Land Figure
1
Approximate Shoreline 1916 EnviroAnalytics Group Tradepoint Atlantic
Area A Boundaries Marsh July 19, 2017
0 375 750 1,500 Area A: Project 150298M
Water Adapted from Figure 2-5 of the Description of Current Conditions Report prepared by Baltimore County, MD
Feet Area B Boundaries Rust Environmental and Infrastructure, dated January 1998 Area B: Project 150300MShallow Sample
@
A Locations
1916 Shoreline
10
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Site-Wide Groundwater EnviroAnalytics Group Figure
0 500 1,000 2,000
Feet
Saturated Slag Thickness (ft)
March 16, 2018
Tradepoint Atlantic
Baltimore County, MD 2Shallow Sample
@
A Locations
1916 Shoreline
500-1,500
>1,500
\\COLUMBIADC01\CorpData\Projects\EnviroAnalytics Group\170194M EAG Groundwater Conditions Summary Report\GIS\Site-wide GW pH and TDS.mxd
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Site-Wide Groundwater EnviroAnalytics Group Figure
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Shallow TDS Concentrations (mg/L)
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Baltimore County, MD 3Intermediate Sample
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1916 Shoreline
500-1,500
>1,500
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Baltimore County, MD
4Shallow Sample
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A Locations
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\\COLUMBIADC01\CorpData\Projects\EnviroAnalytics Group\170194M EAG Groundwater Conditions Summary Report\GIS\Site-wide GW pH and TDS.mxd
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Site-Wide Groundwater EnviroAnalytics Group Figure
0 500 1,000 2,000
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Shallow pH Concentrations
March 16, 2018
Tradepoint Atlantic
Baltimore County, MD 5Intermediate Sample
@
A Locations
1916 Shoreline
10
\\COLUMBIADC01\CorpData\Projects\EnviroAnalytics Group\170194M EAG Groundwater Conditions Summary Report\GIS\Site-wide GW pH and TDS.mxd
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Site-Wide Groundwater EnviroAnalytics Group Figure
0 500 1,000 2,000
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Intermediate pH Concentrations
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Tradepoint Atlantic
Baltimore County, MD 6You can also read
